2021 RETA Breeze Jan-Feb

chemicals to the U.S. Chemical Safety Board (CSB). This regulation applies to any substance that may cause death, serious injury, or substantial property damage. The facility, upon experiencing a release that causes death, inpatient hospitalization, or property damage in excess of $1 million, must notify the CSB. If the NRC is notified of the release, then the facility must notify the CSB within 30 minutes of contacting the NRC. If the NRC is not notified of the release due to not meeting the CERCLA threshold for the chemical, but death, serious injury, or significant property damage has occurred, then the facility must notify the CSB within 8 hours of the accidental release. Bill Lape is Project Director for SCS Engineers. Bill is a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association.

• Did the leak of NH3 last longer than 30 minutes? The time that a leak would have to continue to be reportable would be determined by the typical release rate seem through leaking flanges, valve packings, and pinholes that are most likely to occur in our system. A rate of more than 0.07 pounds per minute will exceed 100 pounds in 24 hours, so the longer the leak goes on, the more likely it will exceed the threshold. For example, a 1/16” diameter pinhole in a hot gas line at 150 psig will exceed 100 pounds in just over 4 hours. A 1/16” diameter pinhole in a high pressure liquid line at 100 psig will exceed 100 pounds in just over 1 hour, even when flashing occurs. When flashing does not occur on the 100 pound liquid line described above due to sub-cooling, it will only take 15 minutes to exceed 100 pounds. It is up to the facility to determine how the employees are going to

It is up to the facility to determine how the

determine if an ammonia release is reportable so that the reports can be made in the allotted time frame to avoid unnecessary fines. There is another, relatively new, regulation that potentially triggers an additional reporting requirement for emergency releases of anhydrous ammonia. 40 CFR Part 1604 was published in the Federal Register on February 21, 2020. It details reporting requirements of significant releases of toxic or flammable employees are going to determine if an ammonia release is reportable so that the reports can be made in the allotted time frame to avoid unnecessary fines.

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